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Comp Blog

Q&A: Are Tabular Disclosures Required on Banners Advertising Credit Card Rates?

By: Danielle Wright

CommentFriday - June 27, 2014

Question:
Although the Schumer box  (tabular disclosures) is required on all credit card applications and solicitations would  the disclosures also be required on internal or external banners advertising a credit union’s reduced credit card rates?

Answer:
No, the Schumer box (tabular disclosures) would not be required on the credit union’s banners. Regulation Z, Section 1026.60, states that the Schumer box disclosures are required on or with a solicitation or an application to open a credit card account. A “solicitation” is defined as an offer by the card issuer to open a credit card account that does not require the member to complete an application. A banner is considered an advertisement and not an offer. As an advertisement, the content of a banner is determined by the advertising rules of Regulation Z Section 1026.16. This section does not require the Schumer box disclosures (or tabular disclosures) on banners or other advertisements.






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